The Government is continuing its engagement with the development industry as mandatory biodiversity net gain (BNG) beds in. HBF has a key role to play in collecting and sharing feedback from members on what is working and what isn’t.

Our feedback seems to be most effective when accompanied by case study examples of planning applications or emerging schemes that are encountering particular difficulties and challenges.

Concerns around emerging Local Plans and the future problems they could be creating in relation to the delivery and implementation of BNG are proving harder to articulate as immediate concerns.

We all know that the progression of Local Plans through the whole plan-making process takes many years. The consequence is that decisions and guidance on plan-making to inform Local Planning Authorities (LPAs) as they progress their plans are needed now.

Currently, there is little BNG guidance on plan-making, and in the absence of clear direction nationally, a plethora of local BNG policies is emerging in both new Local Plans and through Supplementary Planning Documents. The augmentation of national policy and the addition of local criteria that can be found in many of these emerging policies is at odds with how the national BNG system is intended to work.

The result is unnecessary and unhelpful local policy and guidance that creates confusion.

All is not lost though.

Some LPAs are consulting on BNG policies that do add local specificity to the mandatory national requirements and guidance. Perhaps surprisingly this appears to be most successful in emerging plans where the focus is on the bigger nature conservation picture.

When implementing BNG on-site, off-site, or via statutory credits is viewed through the Lawton ecological principles of bigger, better, more joined-up, the tension between the desire for BNG delivery to be as local as possible whilst also delivering maximum BNG benefits is easier to resolve.

The best Local Plan BNG policies recognise the challenges BNG hierarchy presents to the creation and management of on-site BNG, particularly on small sites, and allowing for flexibility.

Policies that set out what information and evidence is needed to move down the BNG hierarchy, from on-site to off-site provision, provide confidence and greater certainty for developers and communities alike. This should also encourage meaningful early pre-applications discussions on which BNG options could deliver the maximum benefits.

In the medium term, there seems to be a real opportunity for Local Nature Recovery Strategies to set out evidence and policy around local priorities for BNG, and for the Local Plan to then be the spatial expression of the Local Nature Recovery Strategy (LNRS). The problem, though, is timing as most LNRSs are still several years away and plan-making must continue in the interim.

HBF’s current asks of government around BNG are therefore:

1. Ensure the 10% BNG system is fully functioning, nationally, before looking to go any further.
2. Require local plans to include a baseline BNG assessment as part of the site allocation process.
3. Ensure Local Nature Recovery Strategies and local plans work together to support off-site delivery and provide confidence about its locations, and when moving down the BNG delivery hierarchy from on-site to off-site is acceptable - especially where this will deliver more and/or better ecological outcomes.
4. Ensure there is clarity in local plans that BNG sites delivering off-site BNG are acceptable in principle in Green Wedges and Green Belt.
5. Stop Local Planning Authorities (LPAs) from producing Supplementary Planning Documents (SPDs) on this matter and instead require them to refer to the national guidance which is already very extensive.
6. Develop a Quality Mark for off-site BNG credits, so builders can have confidence in what they are buying.
7. Ensure the statutory credits systems can deliver BNG benefits, so there can be confidence that schemes that rely on them will deliver the required BNG.

How we’re engaging government

HBF provides feedback directly to MHCLG, Defra and Natural England, and through the Future Homes Hub and Development Industry Group. We contributed to the National Audit Commission’s BNG implementation review and Natural England’s BNG Evaluation Programme being undertaken by Eunomia Research.

We have also been working with the Planning Advisory Service which provides advice for LPAs, to try to ensure all the BNG advice to those involved in BNG is complementary, not contradictory.

We have established a BNG working group.

Our series of BNG webinars for members will continue. Previous webinars are available to access the BNG section of the HBF website if you missed them. This is where you will find other key BNG information and signposting to key documents and evidence.

We will continue to collect feedback on experiences of delivering BNG, both positive and negative, and identify key issues and seek solutions and we will utilise this new blog to help understand and explore any challenges around how BNG policy and delivery are impacting both Local Plans and planning applications. Please do let us know your experiences.

So, to answer the question, HBF is doing a lot to make sure BNG works in practice and does not become a barrier to the delivery of much-needed housing.

If your organisation has HBF membership and you would like to join our BNG working group, contact rachel.danemann@hbf.co.uk.